Ji Eon Kim
Atkoplanning Inc.
Manjangsan-ro, Gwangtan-myeon
Paju-si, South Korea 10951

RE: The tariff classification of composition leather from South Korea.

Dear Ms. Kim:

In your letter dated October 20, 2017, you requested a tariff classification ruling. Samples were submitted with your ruling request and were forwarded to the Customs and Border Protection Laboratory for analysis. This analysis has been completed.

The merchandise under consideration is referred to as Composition Leather (Recycled Leather), ATKO3000. The sample consists of three layers. It is imported in rolls fifty four inches wide. From the information you provided, you state the composition leather is used in the manufacture of automotive interior materials, footwear, handbags, cellular telephone cases and diaries, and upholstery.

Our Customs Laboratory has determined that the article is composed of an acrylic plastic coating layer embossed with a pattern in thickness of .08 millimeter (10.2%). The middle layer consists of a nonwoven fabric layer of nylon fibers (24.6%). The bottom layer consists of leather fibers (composition leather, 65.2%). The bottom layer imparts the essential character.

The applicable subheading for the Composition Leather (Recycled Leather), ATKO3000, will be 4115.10.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Composition leather with a basis of leather or leather fiber, in slabs, sheets or strip, whether or not in rolls; parings and other waste of leather or of composition leather, not suitable for the manufacture of leather articles; leather dust, powder and flour: Composition leather with a basis of leather or leather fiber, in slabs, sheets or strip, whether or not in rolls.” The general rate of duty will be Free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on the World Wide Web at

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Elena Pietron at


Steven A. Mack
National Commodity Specialist Division